Part VI Conflict of Laws, 22 Conflict of Laws
Hugh Beale, Michael Bridge, Louise Gullifer, Eva Lomnicka
- Security interest — Insolvency set-off
22.01 In respect of security in the narrow sense, as well as in the more extended sense that includes title-based financing, the law of secured transactions raises issues that may be either contractual or proprietary in nature. This chapter will deal with cross-border issues in two main areas: first, the choice of law rules for contract and personal property; and secondly, uniform substantive law pertaining to contract and personal property and located in international conventions. The chapter will not deal with jurisdiction and recognition of judgments.1 As will...